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Accepted Manuscript

Title: Towards a regulatory framework for microgridsThe


Singapore experience
Author: Carmen Wouters
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DOI:
Reference:

S2210-6707(14)00115-2
http://dx.doi.org/doi:10.1016/j.scs.2014.10.007
SCS 233

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10-6-2014
20-9-2014
30-10-2014

Please cite this article as: Wouters, C.,Towards a regulatory framework for
microgridsndashThe Singapore experience, Sustainable Cities and Society (2014),
http://dx.doi.org/10.1016/j.scs.2014.10.007
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Towards a regulatory framework for microgrids The Singapore experience


Carmen Woutersa,*
a

School of Energy and Resources, UCL Australia, University College London (UCL), Torrens Building, 220 Victoria Square,
Adelaide SA 5000, Australia
*
Corresponding author: carmen.wouters.12@ucl.ac.uk, (+61) (0)8 8110 9961

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Abstract - Microgrids are increasingly put forward as key concepts of future energy supply
complementing the conventional centralised energy system. This paper describes operational and

regulatory microgrid challenges and makes suggestions regarding how to overcome them. Motivated

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by its unique liberalisation process, state guided growth processes and technology focused economic
and sustainable growth ambitions, Singapore is put forward as a case study. An analysis of its
legislative framework identified that advanced legislation is already in place regarding the distribution

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of locally generated cooling. However, a regulatory framework for full energy integrated modern
microgrids is still in its infancy. Global lessons learned from the Singapore experience are therefore
mainly with regard to utility based microgrids as they might facilitate the set-up of regulatory

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frameworks and standardisation. Additionally, grid connection codes and standards are needed to
ensure safe microgrid operation. Furthermore microgrids still need a legally defined identity. Here,

global best practices are likely to lead the way.

Keywords: distributed generation - grid safety - liberalisation - photovoltaic - Singapore

1. Introduction

Energy is a key driver of industrialised societies. Consequently, in order to deliver energy to

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the consumer, the supply system is required to have high standards with respect to design, operation,

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safety and cost. The growing global population coupled with the growing global energy demand and
climate change issues challenge the current standards and requirements of the energy supply system [14]. Moreover, the finiteness of conventional energy resources such as oil, coal and gas introduces
additional restrictions on the development of the energy supply system [3,4]. As a result, energy supply
is an area of extensive research, which focuses on the challenge to achieve secure, safe and sustainable
energy for the growing global population at an affordable price [1]. The development of new
technologies, such as centralised renewable energy plants, storage, small scale decentralised generation
units, microgrids and smart grids, is expected to play a major role in a momentous transformation of
the conventional energy supply system to a future energy system [5,6]. Especially decentralised energy
generation in the form of small scale, locally controlled distributed generation (DG) units coupled in a
single entity, a microgrid, is of increasing interest to accommodate for the new multidimensional needs
of society [1].

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At the time of writing, research regarding microgrids has mainly been focused on technical
and economic aspects. Technical research is concerned with the effects of decentralised generation on
the conventional electricity network through amongst others bi-directional electricity flows related to
grid safety and islanding. Logenthiran [7] and Mirsaeidi [8] for example, respectively carried out

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research regarding power flow calculations and reviewed the development of innovative protection
systems to accommodate for microgrid operation. Economic research is especially concerned with cost

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benefit analyses, cost optimal design modelling and game-theoretic internal market operation models

[9-12]. Even though such research is advancing the technological and economic barriers, the regulatory

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framework for microgrids is still lagging behind [1]. Marnay et al. [13,14] and Romankiewicz et al.
[15] presented studies of global microgrids together with policy recommendations and existing

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regulations to enable microgrids. A detailed analysis of the appropriateness of an existing national


regulatory framework is however not yet presented to date. The aim of this paper is to analyse the
existing regulatory framework in Singapore regarding several identified microgrid challenges. 1 First,

the position of microgrids within the energy system is presented. Second, operational and regulatory
microgrid challenges are discussed with future lessons for Singapore based on the interaction between

technology and regulation as well as policy recommendations to overcome such barriers in the future.

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Finally, global lessons are drawn from the Singaporean experience.

2. Microgrids and their place in the future energy system

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2.1 The microgrid concept


Today, the microgrid concept has no unique definition since modern microgrids are not
standardised in design but tailored to a specific location and to local requirements [14,16]. The modern
microgrid concept, however, is not new when looking at the evolution of the energy supply system to
what is today known as the conventional centralised energy system since it relates back to the initial

development stages of the electrification in industrialised nations [17,18]. The first electricity grids
emerged in the 19th century within countries that were marked through the industrial revolution such as

the United States, Western Europe, Chile and Australia [17,18]. These first grids were decentral
isolated direct current based microgrids that were privately owned and operated and severed a local
consumer base [17,18]. These local microgrids, based in major load centres, made way for an
alternate current long distance interconnected transmission and distribution network at the end of the
1

This paper uses legal sources but does not employ traditional legal methods. Instead it departs from an engineering perspective
to make regulatory recommendations. The author welcomes feedback and suggestions on the method and presented arguments.

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19th century when the electricity demand and levels of industrialisation and urbanisation started to grow
rapidly [17]. This up scaling of the network led to the centralisation of power plants at the peripheries
of load centres. The latter evolution was coupled with a change in electricity regulation from local to
State control and centrally controlled monopolies with enlarging central power plants owned and

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operated by utilities [17,18]. The energy crisis in the 1970s led to an increase in fossil fuel prices
[17,18]. To counteract the finiteness and dependency on conventional fossil fuels such as coal, oil and

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gas and the dependency on imported primary energy resources as well as to increase energy security by
diversifying the generation portfolio, independent power producers and large-scale renewables, such as

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wind farms, emerged [13,15,17,18]. These new technologies were however still set up within the
conventional centralised network topology [17,18]. The 1980s marked the global start of liberalisation

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of the electricity markets with the introduction of competition forming what we know today as the
conventional centralised energy system which is still mainly based on fossil fuels (see section 2.2).
Within this liberalisation process two trends created favourable conditions for decentral generation to

regain attention [17]. Firstly, the conventional electricity supply structure is under pressure due to
amongst others the growing global population coupled with an increasing energy demand and climate

issues [2-4]. Secondly, full retail contestability of consumers in liberalised electricity markets

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introduced increased consumer awareness in terms of energy efficient appliances and emissions [1].
These trends form a catalyst for a change in philosophy regarding the future energy supply structure [1-

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14]. Local energy generation and supply close to or at the premises of end consumers would help to
accommodate these trends since local generation can exploit the locally available (renewable) energy
resources and can better balance local supply and demand whilst increasing supply efficiency [1,14].
Modern microgrids are here often put forward as key components that balance local supply and
demand whilst potentially coupled with the central grid for increased flexibility and reliability [1,14].
The modern microgrid concept gained increasing interest in the United States as a possible

solution and prevention of black outs after the rolling black outs of 2001 [17,19]. The Consortium for
Electric Reliability Technology Solutions (CERTS) formulated a first definition of a modern microgrid
in 1998 [16]. Also, the European Union showed to be an initiator of microgrid research and
developments through its More Microgrid projects starting in the late 1990s [14,20]. Modern
microgrids are defined on the basis of general characteristics since they are not standardised in design,
but tailored to a specific location and local requirements [14,15,16]. A modern microgrid is a locally

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controlled entity technically defined through three main requirements; (1) comprising both locally
controlled (small scale) generation units (sources), energy loads (sinks), and possible energy storage
units, (2) a potential interconnection with the centralised electricity grid, either on-grid or islanded, and
(3) typically implemented at the low voltage distribution level [2,14,15,16,21]. Microgrids often have a

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single point of common coupling with the grid and thus present themselves as single entities to the grid
[13,14]. The introduction of decentral generation in the form of small scale generation units and

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microgrids, however, introduces grid connection challenges in terms of bi-directional electricity flows,
grid protection, islanding procedures, voltage stability and grid safety [1,22,23].

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The modern microgrid concept is thus not new in that it consists of local balancing of energy
supply and demand. The modern microgrid, however, is not solely a local provider of electricity but is

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also a smart and flexible energy supply system providing electricity as well as other services such as
heating and cooling to its consumers making use of intelligent communication technology, storage and
renewables [1,13,16]. Furthermore, it often complements a connection with the central grid increasing

the reliability of its consumers through islanding capabilities [16]. Microgrids optimise the local supply
and demand of energy through small scale generation units ranging in size from several kW to several

MW in installed capacity [14,22,24]. These units, key components of a microgrid environment, can be

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both dispatchable, such as micro combined heat and power (CHP) units, and intermittent, these are
generation units based on natural resources such as solar and wind [14,22,24]. Small scale generation

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units are often referred to as DG units and are located close to or at the premises of end-consumers in
the grid [22,23]. The potential of waste heat recovery from local electricity generation for heating and
cooling purposes is also an important benefit of microgrids [13,16]. Note that thermal energy supply

refers in the context of this paper to both the supply of heating and cooling which can be achieved
through diverse primary energy resources and generation units.

2.2 The importance of microgrids in the transition towards a future energy system
Energy supply to buildings comprises both electrical and thermal energy supply where
thermal energy supply alludes to the provision of both heating and cooling. Electrical energy supply
conventionally involves a centralised vertical supply structure where electricity is generated in large
centralised power plants and transferred to consumers through the transmission and distribution
networks as explained in section 1 [13]. Thermal energy demand comprises both heating and cooling
supply and is conventionally addressed by self-generation through for example a central heating system
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or an air-conditioning system fuelled by inter alia natural gas or electricity [14]. The conventional
central energy system is today still primarily based on centralised generation using fossil fuels as
energy sources such as coal, oil and gas [4]. Around the world, primary resources used for electricity
generation vary depending on available conventional and renewable energy resources and technologies.

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In 2010 the total global electric energy generated was 21410 TWh [4]. About 65% of this was
generated by fossil fuel plants driven by coal, gas and oil [4]. Figure 1 shows the share of primary

coal
gas
oil
nuclear
bioenergy
hydro
wind
solar PV
other RES

0%

20%

40%

60%

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Yearly electricity
generation

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resources used for the total global electricity generated in 2010.

80%

100%

Figure 1: The distribution of primary energy resources used for the total global electricity generation in 2010, adapted from [4].
RES = Renewable Energy Resource.

The conventional energy supply structure, however, is under pressure [2-4,22,23]. In

response, climate change policy, such as the Kyoto Protocol, already encouraged new low emitting and
efficient energy generation technologies to emerge on a large scale [25]. As of late, this initiated a

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gradual shift towards the introduction of large-scale renewables such as wind and solar parks as well as

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to decentral renewable energy generation such as rooftop PV and small scale wind turbines, located in
buildings and houses as stated under section 1 [1,4,17]. Increasing energy efficiency, decreasing
emissions while balancing local supply and demand will impose new challenges on the system where
decentral energy systems are expected to play an important role to both accommodate for the new
needs of society - such as security of supply, peak load shaving and greenhouse gas reduction - as well
as to complement the conventional system in a smart interconnected network [1,2,4,14,10,22,23,26].
Future energy systems are therefore expected to comprise a greater utilisation of microgrids [2].
Globally, modern microgrids are starting to take up increasing interest. Most currently
existing microgrids are off-grid systems, part of the electrification of rural towns in developing
countries, high reliability systems or trial-systems [14,27-29]. However, grid-tied commercial
microgrids with the option for islanding with seamless transition still experience challenges regarding
protection systems, fault ride-through, reconnection, safety as well as electricity regulations [16,27]. In
2012, the global capacity was estimated at approximately 3200 MW [28]. Here, North America leads
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the way in microgrid research and test trials, having approximately 65% of the global capacity. Europe
and Asia Pacific are starting to catch up with respectively 12% and 9% of the global installed capacity
[28]. The Asian region is also catching up, and in particular Singapore, being a prosperous and
technology-focussed country, is benefiting from the globally established knowledge.

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A major challenge for the widespread adoption of microgrids, however, is the lack of
standardisation and regulations regarding the operation on and off grid as well as both the energy and

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monetary transfers between the microgrid and the centralised grid and between the different microgrid

participants [17,23,30]. The procedure for introduction of microgrids within the conventional energy

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system is an area of extensive debate. Previous research identified that this process can only take place
if governments take up a key role for the roll out of the future grid, focussing on the degree of market

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liberalisation, ownership models, structural operation and design as well as connection issues with the
infrastructure at large [17]. Regarding interconnection, grid codes and standards are already being
formulated around the globe. The Institute of Electrical and Electronic Engineers IEEE Std.1547.4-

2011, Guide for Design, Operation, and Integration of Distributed Resource Island Systems with
Electric Power Systems, is treated as a fundamental technical standard to play a key role for microgrid

interconnection standardisation with intended islanding purposes, including voltage stability standards

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as well as grid safety precautions [29]. Some countries already have regulation in place to enable the
adoption of microgrids. In the United States, for example, regulatory frameworks for microgrids are the

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topic of extensive debate. Several states are identifying barriers for microgrids in their current
legislation (e.g. state Minnesota [31]). In the European Union (EU), the Electricity Directive requires
Member States to define an implementation plan and timetable for the roll-out of smart metering
systems, which is a first step in the right direction for microgrid regulation [32]. Other countries, like
Sweden, already have legislation in place for the sharing of locally generated heat under the form of a
District Heating Act [33]. Similarly to Sweden, Singapore already has legislation in place for the
sharing of locally generated cooling under the District Cooling Act [34]. The presented regulatory
developments may serve as regulatory models for microgrid regulation elsewhere.

2.3 Singapore as an example


Singapore is a state country with over 5 million inhabitants and a high economic standard and growth
illustrated by a GDP of $59813 per capita [35]. Renewable primary energy resources such as wind,
hydro, geothermal and others such as wave energy are not readily available in Singapore to use for
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electricity generation due to its warm and wet tropical rainforest climate and lowland geographical
location [35,36]. Singapore is land scarce and disadvantaged with regard to alternative energy
resources [35,73]. It thus relies heavily for almost all of its electricity on imported fossil fuels such as
oil, coal and gas [35]. The steep increase of fossil fuel prices in the global market has introduced

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challenges with respect to the economic competitiveness and growth of Singapore since the country has
a high rate of foreign investment and import of goods [35]. To facilitate its growing economy in a

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sustainable way, Singapore has taken several measures such as energy efficiency targets and the
ratification of the Kyoto protocol in 2006 [25]. The green strategies and initiatives of Singapore for the

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next two decades are formulated in the Sustainable Singapore Blueprint published by the Ministerial
Committee on Sustainable Development [37]. As part of its National Energy Policy Report, energy

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efficiency, diversification, renewables and research and development are put forward as important
factors to sustain the continuous growth in Singapore [38,39]. The Singapore Initiative in New Energy
Technology (SINERGY) is a fundamental part of its National Energy Policy and includes a centre that

focusses on research, development and testing of microgrids and other future technologies [38]. The
Jurong Island microgrid in Singapore serves as a test-bed for new renewable energy technologies as

part of SINERGY [38]. Microgrid and DG test-beds are also being created by the Singapore Agency

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for Science, Technology, and Research (A*STAR) as well as by the Energy Market Authority of
Singapore, who established a microgrid on the Singaporean island of Pulau Ubin [40-42].

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Singapore is an ideal example for microgrid deployment from a regulatory perspective for

several reasons. First, Singapore has moved to a partially unbundled and liberalised electricity market
without full retail contestability, which facilitates energy supply without competition [43-46].2 This

creates an environment where the energy market is well regulated and transparent which makes an
attractive climate for businesses and foreign investment [35]. Second, Singapore already has advanced
regulations in place for the local distribution of cooling, namely through the District Cooling Act [34].
Third, Singapore defined microgrids as critical elements in its energy strategy [2]. Compared to the
rest of the world, and especially North America, Singapore can however still learn from other countries
with respect to their technology development. Hence, international cooperation is a key part of its

2
Unbundling of the electricity market refers to the structural and legal separation of the four market activities: generation,
transmission, distribution and retail. Liberalisation in this context refers to the introduction of competition in all layers of the
energy system [17]. Full retail contestability is considered as the ideal for liberalised and unbundled electricity markets and refers
to the free choice of retailer for every end-consumer.

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energy policy framework [38]. Last, an observation of the country shows that most inhabitants live in
high-rise buildings or in rural areas [37,47]. The urban structure leaves limited choice for the
inhabitants regarding their preferred type of energy use since this choice falls back on the respective
landlords, which in turn falls back on the utility service providers and the general energy regulatory

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framework of the country [35,47]. Although Singapore is partially liberalised in theory, in practice the
size of the country moderates this liberalisation process [35]. Furthermore, the government has a clear

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vision in favour of economic growth of the country rather than prefacing individual consumer choice,

which dictates the energy climate [35,37]. The small geographical size of Singapore, the well regulated

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and transparent regulatory framework and the openness of its economic and supportive political
structure to (foreign) investment and businesses, makes that new developments can efficiently and

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readily take place [35,37]. This could play in favour of the fast, aligned and coherent roll out of new
technological developments such as microgrids if directed through governmental initiatives.

3. Materials and methodology

3.1 Methodology
This paper analyses the existing regulatory framework in Singapore for identified microgrid

challenges. First, several operational and regulatory challenges of microgrids are identified and the

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governing regulatory framework for energy supply in Singapore is presented. The current regulatory
framework in Singapore is subsequently analysed to find enablers and barriers for microgrid operation,

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which leads to lessons for a microgrid regulatory framework in Singapore, as well as globally.
The analysis in this paper is performed for residential microgrids. Two configurations are

under research, either (1) a neighbourhood consisting of several households or (2) a residential

apartment building. Either configuration has one point of common coupling. Furthermore, to satisfy its
electricity demand, each dwelling has the option to install DG units. 3 In addition, households in a

neighbourhood can interchange locally generated electricity and cooling amongst each other. In case of
the apartment, the generation installed in the building can supply electricity and cooling to all the
households within the building. Moreover, the microgrid as a whole can exchange locally generated
electricity with the centralised grid. The cooling demand is established in the neighbourhood setting
through a central pipeline system where households can share their locally generated cold water from
micro combined heat power cooling (CHPC) systems.4 The cooling demand in an apartment building is

3
4

Dwelling refers to either a single household in a neighbourhood setting or an apartment building as a whole.
Micro refers to DG units with an installed capacity below 10 kW

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established centrally through medium sized CHPC systems and a cooling network throughout the
building.5 Two types of microgrids are thus under research, either a microgrid in its purest form, which
refers to a residential neighbourhood setting where all households can install generation units and share
energy, or a utility owned microgrid, which refers to centrally owned DG units and pipeline networks

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where the individual consumers are served under contract. The operation and local balancing of supply
and demand in either microgrid is managed by a smart microgrid central control system.

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The technologies focussed on in this paper are roof top photovoltaic (PV) units, CHP units
coupled with absorption chillers (AC) and cooling pipelines governing the considered building or

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neighbourhood. Microgrids in Singapore are most likely to consist of CHP units of which the generated
electricity can either be locally used or exported and the waste heat can be used in a district cooling

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system using an AC [34]. Rooftop PV units gain increasing interest due to the favourable climate in
Singapore with an annual average solar irradiation value of 4.56 kWh/m2/day [48]. Table 1 summarises
the characteristics of the considered technologies.

Features

- rooftop panels
- polycrystalline
- fixed tilted,
- Electricity
supply to dwelling
and microgrid

Efficiency/
Coefficient
of
performance
(COP)
Size range

- 12% electrical
efficiency
- 0.15 rated
capacity
[kWp/m2]
1 to 50 kW

Combined heat and


power
unit
(CHP)
[10,50]
- Stirling or gas turbine
- natural gas fuelled
- installed in dwellings
- waste heat utilisation
for cooling purposes
- waste heat demand
driven

Photovoltaic unit
(PV) [10,49]

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Technology

Table 1: Characteristics of the considered distributed generation technologies for a residential microgrid based in Singapore.

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- Electrical efficiency
25%
- Heat to electricity
ratio: 3 kW heat per kW
electricity
1 kW to 1 MW

Absorption chiller (AC) [51]

Pipelines [52]

- hot water fired single effect


- installed in dwellings with
CHP
- CHP waste heat utilisation
- electricity for operation (0.2
KW electricity per ton of
refrigeration)

- temperature
difference
between feed
and return
water 10 C

- COP: 0.7 kW cooling per


kW heating

- 0.1% loss
per meter pipe

2 kW to 1 MW

3.2 Current regulatory framework for energy supply in Singapore


Energy regulations govern both the electric and thermal (cooling and heating) energy supply.

The principle legislation governing the electricity sector and the National Electricity Market in

Singapore is the Electricity Act, which allocates inter alia the responsibilities of the different governing
bodies [53]; and the Energy Market Authority of Singapore Act, which governs the powers of the
Energy Market Authority and wholesale market operation [54]. Recently, developments in the field of
Embedded Generation are made through policies and decision papers [34,55,56]. Singapore relies

Medium refers to DG units with an installed capacity between 10 kW and several 1 MW

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heavily on international investment to drive and develop its economy [44-46,55]. Foreign industries
often make use of Embedded Generation, which is defined as energy generation for internal purposes
on-site and on the same premises owned by the same party [56]. Currently, new Embedded Generation
units have to register with the Energy Market Authority under the Electricity Act if they have a

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generating capacity above 1 MW [57-59]. Under the new regulations, these Embedded Generation
units are also not allowed to export electricity to the centralised grid, unless registered with the Energy

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Market Authority as market participants [59]. Although Embedded Generation units differ from DG
units in installed capacity and regulations (DG units typically range from several kW (micro) up to 1

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MW [16]), the local generation and supply of energy show some similarities.

Regarding thermal energy supply, cooling is needed throughout the year due to the tropical

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climate in Singapore [36]. Most dwellings use air-conditionings to meet their cooling demands [47]. A
district cooling project aiding to increase energy efficiency, is being implemented in selected service
areas [44]. District cooling can be adopted in urban areas and comprises the central generation of

chilled water in a service area. This chilled water is then distributed through a pipeline network to
consumers [60]. This cooling service is established under the District Cooling Act of Singapore [34].

According to the District Cooling Act, a district cooling service is defined under Section 2 as [] the

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sale of coolant for space cooling in a service area by a licensee operating a central plant capable of
supplying coolant via pipe to more than one building in the service area [34]. A centrally owned

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service, which can be seen in case of an apartment building, might facilitate the infrastructure,
regulations and the local market operation compared to a spread out pure microgrid set-up.
3.3 Identified operational and regulatory challenges of microgrids
Five operational and regulatory challenges of microgrids, identified through literature, are put

forward in this paper; (1) an apt legal design for microgrids, (2) liberalisation and competition
requirements, (3) sharing of energy and ownership, (4) the interconnection with larger infrastructure,
including grid safety and islanding procedures, and lastly, (5) the integration of renewable energy
generation units [2,4,15,22,23]. Note that the list of presented challenges is by no means exhaustive. It
puts forward an illustrative example analysis of selected common microgrid challenges. The
aforementioned Singaporean regulatory framework is subsequently analysed for the barriers and
potential to accommodate for the presented challenges.

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4. Microgrids in Singapore: overcoming operational and regulatory challenges


4.1 An apt legal design for microgrids
Currently, no technical or legal definition of a microgrid can be found in the Singaporean
energy regulations [16,15,53]. Moreover, microgrids are tailor-made in design [13,14,16]. The only
global consistency in defining microgrids involves several principles as defined in Section 2. A

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microgrid could, however, be defined inspired by the definition of Embedded Generation, Section 2 of

the District Cooling Act, and the technical definitions given in Section 2 of this paper [14,15,21,34,56].

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For now, a small neighbourhood or building microgrid is most likely treated as a combination of both a
utility energy service, such as a district cooling service, with a total on-site CHP and PV generation

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capacity below 1 MW, which allows DG units and the over-coupling microgrid to export electricity to

4.2 Liberalisation and competition requirements

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the grid without registering with the Energy Market Authority [58].

Singapore has been reforming the structure of its electricity market from a fully vertically

integrated, government owned, electricity supply structure to an unbundled and deregulated electricity
supply structure governed by the National Electricity Market of Singapore [44-46]. This liberalisation

process was introduced in several phases driven by the rapid economic growth and the increasing

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population combined with the quest for an efficient supply of competitively priced electricity to remain
attractive to foreign investors [43-46]. Other industrialised nations, such as Australia and most

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European jurisdictions (driven by the EU liberalization packages such as the Third Energy package),
have also chosen to liberalise their electricity markets, and for Singapore these processes showed a
promising tool to decrease electricity prices due to competitive market operation and to increase grid
efficiency [44-46]. Liberalisation is the first phase of transformation of the energy supply structure [1].
The incorporation of the new climate and energy challenges will introduce a next transition phase
where microgrids could play a central role [1,13].
The liberalisation process in Singapore is to date not completed, but has already resulted in the

unbundling of generation, transmission, distribution and retail [44-46]. Generation is fully competitive,
while the transmission and distribution networks are maintained as a natural monopoly [43-46]. The
retail side is being reformed in several stages. Here the distinction is made between contestable and
non-contestable consumers [61]. Contestable consumers have full retail contestability, whereas noncontestable consumers are supplied through the Market Support Services Licensee, which provides a
fair and equitable electricity price [44]. Currently, residential consumers and other small consumers are
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considered non-contestable consumers [61]. Full retail contestability is thus not yet achieved [62]. The
analysis in this paper is done for residential households in Singapore. Hence it is assumed that this
neighbourhood solely consists out of non-contestable consumers. Although the electricity market in
Singapore is moving towards a fully competitive and liberalised system, the government has a strong

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vision for the states energy developments [35-39,44-46]. The roll out of new technologies, such as
energy efficient CHP generation units, PV units as well as district cooling services could benefit from

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this since the government can create a clear and transparent regulatory climate with a clear microgrid
vision that welcomes foreign investment and businesses.

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Under Section 3 (3)(g)(i) of the Electricity Act, the authority of the Electricity Market
Authority is defined as promoting and safeguarding competition and fair and efficient market conduct

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or, in the absence of a competitive market, preventing the misuse of the monopoly position or market
power [53]. Since there is no full retail contestability in the Singaporean retail market yet there are thus
opportunities for exemptions from the competition requirement under Section 52 of the Electricity Act

[53]. Under Section 3 (3)(g)(i) of the Electricity Act, non-competitive energy supply - like in a
microgrid environment - is permitted as long as this is done without exploitation of the local monopoly

and market power [53]. The tariffs set for non-contestable consumers, served under monopoly retail,

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are regulated under Section 22 of the Electricity Act and are to be set with undue preference regarding
the location of the consumers and with undue discrimination regarding consumers in the same area

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[53]. A similar pricing definition can be found under Section 19 of the District Cooling Act [34].
Furthermore, Codes of Practice such as the Code of Conduct for Retail Electricity Licensees and the
Market Support Service Code refer to maintaining fair energy pricing also for non-contestable
consumers [63,64]. Section 7 of the District Cooling Act states that, unless exempt, [] the occupier
of every premise within a service area requiring air-conditioning shall use the district cooling services

provided by a licensee if such services are available within the service area [34]. Local dominations of
energy supply are thus supported and the local licensee is ensured of consumers. This is similar to what
happens within a residential microgrid environment, especially in utility operated apartment
microgrids. The District Cooling Act thus forms a first basis for locally generated and managed energy
supply, which complies with the exemption on the competition requirement.

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4.3 Sharing of energy and ownership


Similarly to the previous characteristics, no explicit definition of ownership of units and
sharing of energy within a microgrid is accommodated for under the Electricity Act. Nevertheless,
ownership is defined on several occasions regarding the regulations on both district cooling and

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embedded generation. Two types of ownership are distinguished: first, the ownership of generation and
supply facilities such as the PV units, CHP units, ACs and cooling pipelines, and second, the

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ownership of the locally generated energy and the internal microgrid market.

First, with regard to the ownership of generation and supply facilities, both the District

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Cooling Act and the Decision papers on Embedded Generation provide certain relevant definitions. In
the situation of District Cooling facilities, a licensee is defined under Section 2 of the District Cooling

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Act in relation to any service area, as a person who is authorised by a licence to carry out all or any of
the functions of providing district cooling services to the service area [34]. The consumers still own
their land and their houses as stated under Section 28 of the District Cooling Act [34]. This private

ownership definition combined with public/state/utility ownership of the cooling distribution system
will have an impact on the implementation of infrastructure necessary to establish the cooling network.

Concerning Embedded Generation units, the revised rules of the Energy Market Authority state that the

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Embedded Generation unit, the load facilities of that unit and the land on which the unit is built should
be majority owned by the same company [59]. The company is additionally not allowed to export

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electricity to the grid unless it applies for a license for the Embedded Generation unit to be a
commercial generation unit that participates in the wholesale electricity market [59].
Second, regarding the operation of the internal market and ownership of locally generated

energy, no precedent can be found within Singapores legislation. Models regarding ownership and
service with respect to microgrids have, however, been proposed in literature. Nyserda [21] refers to
several models developed by King [65] that categorise microgrids regarding their ownership and
business practices. Microgrids in their purest form are referred to as local cooperative neighbourhoods.
Practically, in case of a residential microgrid in its purest form this implies that the ownership
of the equipment, such as pipelines, CHPC systems and PV systems - which are not necessarily
installed in each household - should be decided upon by the cooperating households. This introduces
issues with regard to who owns and maintains those units that serve the whole neighbourhood but are
not necessarily installed in all households. If a utility owned microgrid is installed, the utility will

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install a medium scale CHPC system as well as a district cooling network and might require each house
to install a certain rooftop PV capacity. The utility can then serve the connected households under
contract. When looking at a single apartment, the microgrid system is inherently utility owned. One
medium size CHPC system can be installed which provides cooling and electricity to the different

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apartments in the building. Also a larger capacity of rooftop PV units can be installed on the roof of the
building to supply the consumers.

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The Singaporean legislation accommodates for a precedent of a microgrid environment that is


supplied and managed by a single licensee in a certain service area, this is, a utility owned and operated

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microgrid, through the District Cooling Act. The consumers within that service area, however, must

4.4 Interconnection with larger infrastructure

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accept the energy supply from that licensee unless exempt (Section 7 of the District Cooling Act [34]).

With respect to the connection of a microgrid with larger infrastructure, several challenges are

introduced. First, licensing requirements are researched, second, grid access options combined with
grid safety issues, third, islanding authorisation, and fourth, the responsibility to provide for additional

energy infrastructure required for microgrid operation and the sharing of locally generated energy.
First, in the decision papers regarding Embedded Generation, the licensing requirements of

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on-site generation units are stated [58]. Microgrids are made up out of DG units that are typically

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several kW in electrical capacity in a residential setting and are thus exempt from registering in with
the electricity market [58,66]. Additionally, Section 6 of the Electricity act states that a license or an
exemption is needed to engage in electricity activities. Microgrids therefore need to make sure they are
in accordance with the licensing requirements as they not only import and export electricity but also
engage in the generation of electricity and potentially retail. Schemes are already provided for the
installation of both rooftop PV units with grid export capabilities under the Handbook for Solar
Photovoltaic Systems of Singapore as well as embedded generation units [67]. Here, non-contestable
consumers do not need to apply for a generation license nor register with the Energy Market
Commission as market participants to export electricity in exchange for compensation [67]. This is in
contrast with the procedure for Embedded Generation units since they are obliged to register with the
Electricity Market Authority [58]. A special treatment lies in the operation of a so-called Master-sub
metering scheme, which can be found in inter alia private condominiums and commercial buildings
[67]. A residential apartment building configured as microgrid falls under this category. Under this
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metering scheme, the total facility has a single point of common coupling and the electricity that each
sub-unit attempts to export to the centralised grid may be used up by the common services or by other
sub-units within the facility [67]. The drawback under this scheme is, however, that sub-units cannot
rely on compensation for exported electricity, since the actual amount of exported energy per sub-unit

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is untraceable [67].
Second, with regard to grid access, the Energy Market Authority provides non-discriminatory

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access to the grid as stated under Section 3 (3)(g) of the Electricity Act [43,53]. Electricity generating
units thus have the right to access the transmission infrastructure. Furthermore, the open access

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principle (as opposed to firm access) is adopted for network planning in Singapore [68]. This principle
states that the transmission licensee has no obligation to reinforce the network, whether to mitigate

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transmission constraints beyond the connecting substation or otherwise [68]. This implies that there is
no guarantee for the transmission network to be constraint free or for the generation units to fully
utilise the transmission infrastructure [68]. Microgrids should thus be able to legally connect to the grid

without discrimination if the open access principle is extended to the distribution network. The export
of energy to the grid, however, is subjected to congestion management. Additionally, internal

microgrid operation as well as the connection of a microgrid to the central grid introduces bi-

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directional electricity flows that require grid reinforcement since the central grid does not foresee
bottom-up supply of electricity introduced by decentral generation at the distribution level [4,16,22,23].

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The operation of conventional protection systems in the distribution grid has to be adapted in order to
isolate faults in the network in two directions to maintain safe operation. Furthermore, the installation
of renewables such as rooftop PV units can affect the voltage stability in the network, which can also
compromise grid safety [22,23]. The connection of DG units as well as microgrids to the centralised
grid thus has to be in accordance with the technical standards such as the Transmission Code and the
Metering Code [69,70].

Third, authorised islanding is a major advantageous characteristic of microgrids as it increases

reliability of the consumers and allows a microgrid to disconnect from the central grid when required
and work autonomously [14,16,66]. The problem with islanding is that after the microgrid is isolated
from the central grid due to a fault in the latter, the microgrid by itself has to operate under safe
conditions after a short ride through period [14,16,66]. Since voltage stability issues, safety of
operation due to bi-directional power flows and the small size of the network challenge safe operation,

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islanding is often prohibited under network regulations [71]. Anti-islanding requirements for
generation units are, however, not explicitly mentioned in the Electricity Act. Several sections of the
Act, amongst others Section 3 (3)(e), Section 39 (1), Section 94 (3) and Section 103 (m)(iii) refer to
safe operation of the DG units [53]. The Transmission Code has standards in Appendix C, Section 4

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(e), regarding protective devices and mentions islanding in one paragraph as being an option to supply
a load [70]. It therefore appears that islanding is not prohibited under the Singaporean regulations.

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Last, energy integration of a residential neighbourhood with microgrid configuration needs

additional infrastructure that might cross publicly and privately owned land. Under Section 28 of the

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District Cooling Act, regulations are already formulated regarding the inspection, maintenance, repair,
removal and alteration of cooling pipelines that run through privately and publicly owned land [34].

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The Electricity Act addresses electrical supply infrastructure amendments over state lands by an
electrical or a supply installation licensee under Section 69 (1), Section 71 (b) and Section 71 (c) [53].
Additionally, the Singapore Public Utility Act has provisions regarding the electrical and water supply

infrastructure under Section 24A (9), Section 32 (2) and Section 38 (2) [72]. Noteworthy is that
exemptions to the provisions under Part IX Section 71 (b) and Section 71 (c) of the Electricity Act

might be granted by the Energy Market Authority for any electrical or supply installation used

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exclusively for domestic purposes or other installations where it is considered desirable [53]. This latter
section appears to leave room for the implementation of residential, this is, domestic, generation units

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regarding licensing and any other provisions under Part IX of the Electricity Act.
4.5 Integration of renewable energy generation units
As explained, future energy systems would not only allow for centralised renewable energy

generators, such as wind farms, to be connected to the grid, but would also integrate renewable DG
units. Microgrids are able to exploit locally available energy resources and can thus facilitate the
incorporation of widespread locally controlled renewable energy sources in the system [1,22,23].
Solar and biofuels are most the favourable renewable energy resources to aid Singapore in its
sustainable economic growth [35,73]. Singapore has limited PV units installed due to their cost and the
prevalence of apartment buildings [74]. The installed capacity of PV units is however increasing.
Singapore has currently no feed-in tariff in place but a compensation for electricity exported to the grid
by residential PV units [75]. Non-contestable consumers applying for the latter are compensated for
exported electricity through a credit adjustment of their monthly electricity bill [67]. Under the Master16

Page 16 of 25

sub scheme, no compensation is given to the sub-units, since part of their exported energy is used to
supply auxiliary common services of the facility, which cannot be quantified through the single meter
[67]. Singapore thus still has growth potential regarding the implementation of renewable DG units and
metering, especially in the residential sector. This growth could be achieved in a residential microgrid

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environment.

4.6 Overcoming challenges in the future

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Singapore has with its District Cooling Act and decision papers on Embedded Generation

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already advanced legislation in place that can serve as a starting point to accommodate for residential
microgrids employing rooftop PV as well as district cooling services. However, based on the identified
challenges, some recommendations can be made to increase microgrid deployment in Singapore.

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First of all a legal definition of a microgrid should be outlined in order to construct a


supporting regulatory framework. Since microgrids have characteristics of both energy consumers and

producers, an appropriate operational structure of a microgrid should be spelled out to clarify their
place in the market. This can inter alia be a utility owned and operated microgrid or a cooperative

microgrid and can either be from a consumer or producer perspective. Since most of the Singaporean
population lives in apartment buildings, centrally managed utility based microgrids are most likely to

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be rolled out due to the ease of standardisation and the set-up of the regulatory framework.

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Second, the Electricity Act provides exemptions from the competition requirement that
characterises liberalised energy markets, for example under the District Cooling Act. Even more so, the
District Cooling Act encourages local energy provision dominances. Microgrids are not fully
competitive but allocate generation units optimally and share the locally generated energy. They might
thus be able to be established under Singaporean law since non-competitive retail is inherently not
prohibited, and sometimes even encouraged. In a utility-based apartment microgrid, the principles
governing the District Cooling Act can be readily extended to include an electricity provision service
from a central CHPC system and rooftop PV installed in the building.
Third, the sharing of the locally generated energy and the ownership of the generation units,
however, still needs to be accommodated for. Though, Singapore has with its District Cooling Act
already a legislative framework in place for utility operated and serviced neighbourhoods regarding
coolant supply. This is a first step towards the local generation and operation of both cooling and
electricity supply within a service area or neighbourhood. It provides an example for a utility owned
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and operated microgrid which can be adopted in apartment based microgrids. Microgrids in their purest
form are, however, more complex in terms of private ownership, licensing and contractual agreements.
Fourth, regarding the interconnection of microgrids with the larger infrastructure, there are no
specific licensing requirements with the Energy Market Authority for residential microgrids.

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Furthermore, microgrids could be able to legally connect to the central grid infrastructure without
discrimination due to the open access principle. This removes connection barriers for DG units,

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provided they follow the Transmission Code and technical standards in their connection procedure to

ensure safe operation in an environment with bi-directional electricity flows. Nevertheless, for a

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microgrid to be able to rely on support mechanisms, more elaborate metering schemes and
compensation mechanisms should be put into place, especially to identify the share of individual

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households within a residential microgrid. Furthermore, the Singaporean Electricity Act and
Transmission code have no explicit anti-islanding provision. This might additionally facilitate the

operating in island mode should be ensured.

implementation of residential microgrids. Here, however, safe operation while transitioning to and

Fifth, renewable energy DG units are not common yet in Singapore due to its climatic and

geographical conditions. Sun, however, is abundant. Hence, rooftop PV units are emerging in the

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residential sector. A stronger supporting framework with feed-in tariffs or tax reductions and an
adequate metering scheme for all consumers could aid to the widespread implementation of these units

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as well as other high efficient micro and medium cogeneration units, diversifying its generation
portfolio and reducing its dependency on imported fossil fuels.
Despite the interest in microgrid test facilities in Singapore, several operational and regulatory

issues still need to be addressed in order for microgrids to be established on a large scale. The main
barriers in Singapore are identified as being (1) support and advanced metering schemes for DG units
as key components of the microgrid, (2) ownership and internal market models for cooperative
microgrid neighbourhoods, and (3) codes for safe operation especially in island mode.

5. Lessons learned
Although it can be argued that Singapore is not yet a leading nation with respect to microgrids
from a technological point of view, due to its unique legal framework, governmental initiative and
transparent regulatory climate, it could unarguably inspire other countries. Microgrids have specific
characteristics and face operational and regulatory challenges, of which several were discussed in this
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paper. From the analysis of these challenges in Singapore, some lessons can be formulated for other
countries wanting to deploy microgrids in their (future) energy systems.
First of all, it is essential for countries to identify their building structures and available
renewable energy resources to develop the most suitable legal microgrid definition within their

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legislation [13,66]. A microgrid can be defined as a consumer or producer of energy and its operation
can be organised in for example a utility or a cooperative neighbourhood depending on where the

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existing regulation provides an apt playing field [65]. The choice of legal identity is of major

importance as this will determine the required regulatory changes. The chosen approach, however,

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must be carefully selected since it determines who is responsible for operating the microgrid and
interconnecting it with the central grid. This in its turn has consequences regarding access to the grid

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and competition requirements. Utility owned and managed microgrids that serve their consumer base
under contract and manage small or medium DG units are expected to be most attractive in terms of
standardisation, organisation and regulation. The Singaporean District Cooling Act can here be put

forward as an example of a utility owned energy provision service.

Second, many countries are evolving towards liberalised electricity markets and competition

requirements are one of the keystones of their energy market policy [76]. Often, liberalisation of the

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energy market is coupled with a free choice for all end-consumers regarding their retailer. This has
consequences for utility owned microgrids since it could be argued that consumers within this service

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area have no choice of retailer. Consequently, microgrids may need an exemption from certain
competition requirements that characterise liberalised electricity markets.
Third, the analysis in this paper showed that Singapore has, despite its liberalisation process,

still a strong governmental vision in terms of its energy system. This is combined with a transparent
and well-regulated market that encourages (foreign) investment and businesses. The roll out of new
technologies such as microgrids and location specific DG technologies can be established readily and
efficiently with a clear governmental direction and guidance. Jurisdictions around the globe can learn
from this in that they should identify and formulate a clear vision for microgrids and DG units and
increase transparency of the regulatory climate governing the energy system to attract investment.
Fourth, to be able to connect a microgrid to the energy infrastructure at large, standards and

codes regarding grid connection have to be taken into account. These might not allow generation units
to be connected at the distribution level or might disadvantage their connection [13,14,66]. A microgrid

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connection with the centralised grid could namely introduce technical issues that need additional
investments to ensure safe grid operation especially when looking at islanding as an option for
microgrid and DG operation [2,5,15,71]. Furthermore, regulations regarding islanding have to be
evaluated [15]. Often, centralised electricity networks and their operators require for any generation

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unit in the distribution grid to switch off in case of a fault on the higher level in the centralised grid
[71]. Anti-islanding requirements can therefore form a barrier to microgrid implementation with

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intentional islanding purposes [66,71,77]. Although there are currently no regulations directly
prohibiting the connection to the central grid and the islanding of microgrids within Singaporean

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regulations, Singapore could consider to adopt additional grid codes to ensure the safe operation of the
network under bi-directional flow conditions [71]. The potential of jeopardising safe grid operation is

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namely identified as one of the main barriers for the wide spread introduction of microgrids and DG
units within the central grid [71,77]. Countries around the world already have grid connection codes
and national standards for decentral generation units that Singapore can take notice of. These

connection standards and codes are related to, amongst others, maximum installed capacity of
generation units at different voltage levels, power factor and grid protection requirements due to bi-

directional electricity flows as well as voltage stability and frequency requirements and islanding

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procedures to ensure safe grid operation [22,23,71,77]. In the United States for example, several states
have DG interconnection guides and procedures characterised by the IEEE 1547 standards [29].

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National Grid [78] for example, gives the procedures for the connection of DG units in the New York
area. Within Europe, the United Kingdom has several standardised connection requirements and codes
for DG units developed by the Office of Gas and Electricity Markets (ofgem) [79], this is, the ER
G83/1 standard, and by the Energy Networks Association [80], ER G59/1 standard. Towards the future,
the European Commission is setting priorities for the ACER and ENTSO-E to develop network codes
that will eventually apply directly across Europe in the same way as EU regulations [32,76].6
Fifth, since future energy systems emphasise renewable energy as part of the generation mix,

they should be looked at in conjunction with microgrids. State specific regulations might include

ACER = Agency for the Cooperation of Energy Regulators, ENTSO-E = European Network of Transmission System Operators
for Electricity. See for instance: European Distribution System Operators for Smart Grids (http://www.edsoforsmartgrids.eu/wpcontent/uploads/EDSO-response-to-network-codes-priorities-for-2015-and-beyond.pdf).

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restrictions on installed capacity of renewable energy generation units or other DG units, as well as
support policies that promote the implementation of small-scale generation units such as feed-in tariffs
or a credit system [82]. Having a support scheme in place causes the implementation of microgrids to
be economically attractive due to the potential to create an income [13]. An additional requirement is

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an adequate metering system to allow for support schemes to take action, especially in microgrids
where the individual participants as well as the microgrid as a whole have to be monitored. Restrictions

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on consumer data collection and consumer privacy, however, might disadvantage this [16,83].

Even though global lessons can be a useful exercise, at least for operational or policy trends,

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microgrids are part of the national energy supply, which is mainly regulated at a national level. Hence,
a regulatory framework is likely to be established either through private contracts between microgrid

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participants or through a centrally utility serving a consumer base under contract. Since microgrids are
tailored to specific regional climatic conditions as well as political environment, chosen energy

Some general lessons can however be drawn:

resources and regulations are too and will therefore not necessarily be transferrable amongst countries.

A central utility operated residential microgrid might facilitate the regulatory process and

National standards and codes for grid connection of DG units and small microgrids are

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standardisation. The District Cooling Act of Singapore can here be put forward as an example.

already in place in some countries with liberalised electricity markets [6]. A revision of these

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standards, however, is desirable to ensure microgrid operation.

Further research could compare operational microgrids to assess the geographical and political reasons,
enablers and barriers to identify why some microgrids succeeded and others failed. Furthermore, the
question whether or not it is realistic to set up a microgrid in its purest form instead of focussing on
utility owned microgrids should be explored in more detail since the latter might facilitate the
regulation, standardisation and unification process.

6. Conclusions
The increasing interest in and recognition of microgrids as key concepts for future energy
supply has already initiated extensive engineering and economic research. Regulatory frameworks for
microgrids, however, are still in their infancy and will be the next challenge to enable microgrids to
globally emerge on a large scale. The appropriateness of current Singaporean regulatory framework for
microgrid operation was analysed as a case study for identified operational and regulatory microgrid
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challenges. Although it can be argued that Singapore is not yet a leading jurisdiction for technical
microgrid development, it was chosen as a case study due to its unique legal framework and
liberalisation process as well as its transparent and business friendly regulatory climate.
Analysis of Singaporean energy regulations determined that it already has advanced

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legislation in place regarding the distribution of locally generated cooling that can serve as a basis for a
regulatory framework for residential microgrids in Singapore under the District Cooling Act. Although

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Singapore has a potential regarding decentral generation, the cost and limitedness of support

mechanisms and metering schemes hinders widespread adoption. Moreover, competition and islanding

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are not prohibited under the Electricity Act and Codes of Practice, which leaves the door open for
microgrids if additional standards and grid connection codes are developed to ensure safe operation

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under bi-directional electricity flow conditions. The main barriers for microgrid operation in Singapore
are identified as being (1) support mechanisms and advanced metering schemes for DG units, (2)
ownership and internal market models, and (3) codes for safe operation especially in island mode.

Microgrids are part of the national energy supply. Some general lessons can however be made
from the Singapore experience. A central utility owned and operated residential microgrid might

facilitate the regulatory process and standardisation. The District Cooling Act of Singapore can here be

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put forward as an example. Microgrids furthermore still need a legally defined identity to standardise
and generalise its operational procedures as well as grid connection codes and procedures to ensure

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safe operation. Here, countries can learn from each other in setting up standards and regulations for
microgrids from a technical perspective through the adoption of global best practices.

Acknowledgements - C.W. gratefully acknowledges the financial contribution from BHP Billiton in the form
of her PhD scholarship, the guidance received from her supervisors at UCL, Dr. A.M. James, Prof. E.S. Fraga and
Dr. E.M. Polykarpou, the extensive comments, feedback and guidance received from Dr. K. Van Hende, Lecturer
at UCL Australia, as well as the advice received from C. Vigar, Wallmans Lawyers, Adelaide.

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